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We are currently re-competing a contract for Operation and Maintenance of a remote Air Force Station.  The Government owns a lot of property at the site that will be very useful to the winning contractor in performance of the contract (hand tools, maintenance equipment, shop stock, etc.).  It doesn't make sense to provide this property as "Government Furnished Property" because it doesn't clear the hurdles of FAR 45.102.  But it also doesn't make sense to turn this property in to DRMO or to scrap it, only to have the winning contractor purchase much of this same equipment all over again.  So my question is, can we provide listings of all this property and have contractors bid in a "discount" to be able to take possession of it all?  In other words, we would basically be selling the Government property to the winning contractor, the price of which would just be deducted from their overall bid.

Is this a viable strategy?  Does anybody have any experience doing something like this? 

 

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I recommend reviewing the GSA Federal Management Regulation (FMR), formally the Federal Property Management Regulation, at 41 CFR Part 102-39.  Absent of any specific law, regulation or waiver from GSA, DOD and civilian agencies follow the FMR for the disposal of personal property (DFARS Subpart 217.70 and FAR Subsection 45.604-4, respectively).  The FMR has significant limitations on an agency's ability to sell personal property directly.  The FMR allows agencies to:

* Transfer:  Conduct direct transfer of equipment to another federal agency, including GSA;

* Abandon:  Abandon or destroy excess personal property when an authorized official of the agency makes a written determination that the personal property has no commercial value, or that the estimated cost of its continued care and handling would exceed the estimated proceeds from its sale; or

* Exchange:  Exchange or sell similar items, when acquiring replacement property, and apply the exchange allowance or proceeds of sale in whole or in part payment for the property acquired.

Only GSA has authority to sell government property outside of an exchange or other exceptions mentioned.   

See FMR Part 102-35, Disposition of Personal Property, and 102-39, Replacement of Personal Property Pursuant to the Exchange/Sale Authority, for more information:

http://www.gsa.gov/portal/ext/public/site/FMR/file/FMRTOC.html/category/21856/hostUri/portal

 

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I'm unclear as to the relationship between the incumbent contractor and the government's inventory. How did the government acquire title? Is the inventory contractor-acquired (and reimbursed) under a cost-type contract? If not, what's the story?

Does the winning contractor need to acquire title, or can it simply be permitted to use the government's inventory at no cost (which would be a cost avoidance)?

Hope this helps.

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Thank you everybody for your input. I'm running around trying to figure this stuff out on the fly between other work, so I don't have time to give comprehensive answers to the questions, but as soon as I have a decent opportunity I will answer the questions and provide more information. Thanks again to each of you!

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On ‎6‎/‎21‎/‎2016 at 8:20 PM, Scorpimouse said:

We are currently re-competing a contract for Operation and Maintenance of a remote Air Force Station.  The Government owns a lot of property at the site that will be very useful to the winning contractor in performance of the contract (hand tools, maintenance equipment, shop stock, etc.).  It doesn't make sense to provide this property as "Government Furnished Property" because it doesn't clear the hurdles of FAR 45.102.  But it also doesn't make sense to turn this property in to DRMO or to scrap it, only to have the winning contractor purchase much of this same equipment all over again.  So my question is, can we provide listings of all this property and have contractors bid in a "discount" to be able to take possession of it all?  In other words, we would basically be selling the Government property to the winning contractor, the price of which would just be deducted from their overall bid.

Is this a viable strategy?  Does anybody have any experience doing something like this? 

Who has fiduciary responsibility for the equipment now? 

 

 

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Okay I have a moment so I will try to answer all the questions.

 

Don – Why not?  First, there is a lot of property on site that *will* be issued as GFP.  Items that are mission-specific, special tooling, TMDE equipment, benchstock and equipment on CA/CRL lists will be provided as GFP.  But we also have a lot of “supplemental” items – things like buckets of nuts and bolts, tools, coils of copper piping, small appliances like vacuums, and other things that aren’t accounted for on any official equipment list.  These supplemental items do not, in my view, clear the thresholds in FAR 45.102 (a) and (b) which states:

(a) Contractors are ordinarily required to furnish all property necessary to perform Government contracts.

(b) Contracting officers shall provide property to contractors only when it is clearly demonstrated—

(1) To be in the Government’s best interest;

(2) That the overall benefit to the acquisition significantly outweighs the increased cost of administration, including ultimate property disposal;

(3) That providing the property does not substantially increase the Government’s assumption of risk; and

(4) That Government requirements cannot otherwise be met.

 

ji20874 – Yes, thank you – the idea would be do something similar, only on a somewhat larger scale.

 

metteec – Thanks for the guidance.  Yes, I am aware of it and have reviewed it (I admit, I may not have it all digested correctly).  Based on my reading, it seems to be geared towards property that is: 1) officially accounted for, 2) is no longer needed, and 3) is wanted to be gotten rid of.  In our case we don’t meet any of those three conditions.  Based on my reading, we may fall into the “exchange/sale” authority in 102-39, which states, “ ‘Exchange/sale’ means to exchange or sell non-excess, non-surplus personal property and apply the exchange allowance or proceeds of sale in whole or in part payment for the acquisition of similar property.”  Only instead of “exchanging” property for property, we would basically be exchanging property for a service.  What do you think?

 

here_2_help – This contract has been ongoing for decades, so over the years the site has accumulated various items.  Way back in the day, some of the equipment was bought directly by the Air Force and that Government property remains on site to this day.  For the most part though, the Government acquired title because the incumbent contractor over the years bought items using a Cost Reimbursable CLIN so title rests with the Government.  The winning contractor does not need to acquire title (although that is what my question pertains to – we would like them to).  They could simply take possession of the property for their use without acquiring title to it, but one of the things that is driving this question is the new Financial Improvement Act Reporting (FIAR) requirements.  FIAR came about (in part) because the DoD did not have a good accounting of their property.  So based on my understanding, FIAR says that ALL Government property that is used on contracts must be officially accounted for, which means it needs to be documented and uploaded in EDA.  But as I said to Don (see above) I think providing all this property in that manner goes against the intent of the FAR because the Government still has ultimate responsibility to acquire, manage, track, maintain and dispose of it.

 

BowtechDan – Currently the Government ultimately has fiduciary responsibility.

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Scorpimouse,

Yes the govt has fiduciary responsibility.  But what govt entity owns the equipment? The USAF?  What office/squadron,etc? Did they make the decision to provide GFP  IAW PGI 245.103-70?

 If you are providing GFP to the contractor (KTR) and the contract has 52.245-1 (and subsequent clauses as prescribed), the KTR is required to have a Property Management System of internal controls to manage (control, use, preserve,protect, repair, maintain) our equipment.  This equipment should be on a list as an attachment to the contract IAW the PGI 245.1.  When the new KTR comes in, the old/new KTR should do an inventory, reconcile any losses,and then the CO would do modifications to transfer the GFP list from the old to the new contract (two mods).

 

As stated in your previous post, the KTR does not take "title" to GFP.  When they buy equipment or materials on a cost CLIN and we reimburse them, the title is now to the govt.  The KTR has "stewardship" and will manage it IAW 52.245-1 and their property management plan,but we have "title" to it.


You mentioned the FIAR. All GFP provided to KTR's shall be included in our (USAF unit who owns the equipment) property books. DoDI 5000.64, ENCL 3 states:

3. PROPERTY FURNISHED TO A THIRD PARTY. Although the Department of Defense may not have physical custody, in order to maintain effective property accountability and for financial reporting purposes, DoD Components shall establish and maintain records and accountability for property (of any value) furnished to contractors as Government furnished property (GFP). This requirement also includes property that is loaned to outside entities such as Federal agencies, State and local governments, and foreign governments. <end>

That would be the USAF PBO responsibility.

 

I recommend you find an 1103 Property Administrator in your agency and get this contract back on track in regards to GFP. If the GFP currently on hand is needed to perform the contract, you don't sale it and buy new........you transfer from one contract to another via a mod. But if the GFP isn't officially on the contract, it should be.

 

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BowtechDan,

Ah I'm tracking you now. I misunderstood your question.

Let me make a distinction. There are two "types" of property on this contract and that I'm talking about. The first is that property that *is* and *should* be "GFP." This is the category that you're addressing, and yes the contract is square on that front - the clauses are in the contract, the property is attached to the contract, accounted for, inventoried, and transferred IAW the FAR and FIAR.

The second category, which my question pertains to, is the "other" Government property on site. This is the stuff that has accumulated over the years and does not fit the FAR criteria to be provided as "Government-Furnished Property."  As for fiduciary responsibility, this property is not officially accounted for anywhere in the Air Force except for the lists maintained on site - it's not in any database. It's the type of miscellaneous property I've described above.

So the way I see it, in light of FIAR, we have basically two options.

1) If it stays as Government property, it will have to be issued as "GFP" and attached accordingly. However, I don't believe it's the intent of the FAR to provide all this miscellaneous property as GFP.

2) The other option is to clean up our books by transferring title to the contractor, by having them bid on it, effectively reducing the price of the contract.

The way I see it, everybody wins - we are FIAR compliant, the books are clean, we have met the intent of the FAR, the contractor gains useful equipment, and the Government gets value back for the equipment it is giving up.

 

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4 hours ago, Scorpimouse said:

The second category, which my question pertains to, is the "other" Government property on site. This is the stuff that has accumulated over the years and does not fit the FAR criteria to be provided as "Government-Furnished Property."  As for fiduciary responsibility, this property is not officially accounted for anywhere in the Air Force except for the lists maintained on site - it's not in any database. It's the type of miscellaneous property I've described above.

Now I understand what you mean by "not clearing the hurdles of 45.102". It sounds like a govt problem with "stuff" accumulating that needs cleaned out. If the property isn't on contract, and isn't needed to support the contract, it's not "contract" GFP.......it's stuff the USAF needs to get rid of from their govt installation. Normally that would be DLA Disposition Services (formerly called "DRMO"), but I don't know what the USAF process for equipment turn-in is.

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Scorpimouse,

So the primary business objective here is to get the miscellaneous crap that's accumulated over decades off the Air Force's books. You are looking at options as to how to best make that happen and you want to make it the new O&M contractor's job.

I like your second option and I think it makes sense for the taxpayers. Are you contemplating a separate CLIN where the contractor bids a credit (negative cost) for the miscellaneous crap? Or perhaps its Not Separately Priced? In any case, you probably need a listing of what the crap is (which is not all that different from an inventory and upload, right?). I'm guessing a site visit and bidders' walk won't be sufficient to identify all the crap the bidder is getting, unless you have it all separately located and identified. If you do, then I think this is the way to go.

Another option is simply to abandon in place but, as noted above, that involves paperwork and a list of what's being abandoned. I get that you want to avoid inventorying the accumulated crap.

Another option might be to have all bidders show a price reduction of $XX.XX uniformly. Just put that value in the pricing instructions. That way there's no competitive advantage from "mis-estimating" the value of the miscellaneous crap, and nobody can say the government was unjustly enriched because they were misled into exchanging money for nearly worthless crap like buckets of rusty screws. After award, the new contractor takes title for the contractually specified price.

Another option might be to have a mandatory task to inventory all the crap and then auction it off, with the government receiving the funds. This approach assumes the cost of inventory and auction is not dramatically more than the amount to be received. (It probably will be.) If I know my O&M contractors (and I do) then the O&M will want a cost-reimbursement CLIN because the scope of the effort can't be known up front. Which means lots of expensive labor hours (probably at SCA rates).

Just my random thoughts on an interesting challenge.

Hope this helps.

 

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BowtechDan - Yes, for the most part what you've stated is accurate.  But one thing I want to emphasize is that this property isn't "junk."  For the most part it's low-dollar equipment but of the type that will be very useful in the performance of the contract.  Also, it's property that is *not* used by the Government for Government purposes, but is used by the contractor for contract purposes.  Part of what we're thinking of doing is allowing the Government personnel on site to reutilize whatever of this property they want for their own purposes, and then whatever is left over will be turned over (or "sold") to the contractor (that way we don't lose control of a piece of property it turns out we really needed for our own Government purpose).

here_2_help - Yes, you have the idea exactly right.  We are thinking exactly of having a separate CLIN that will be "negatively priced."  We do have lists and pictures that will included in a bidder's library, and we'll also have a sight visit so prospective offerors can lay eyes-on for themselves.  The idea is to have this negatively priced "credit CLIN" be included in the their Phase-In proposal, which will not be evaluated as part of the Total Evaluated Price so as not to give the incumbent an advantage.  We're trying to come up with a way that, as you said, makes sense for the taxpayers, while at the same time makes sense for the contractor and the Government.  We think this might work.

Thank you all for your very valuable and helpful feedback.  I love this site for just this reason - very knowledgeable people are willing to share their different experiences and point out something I may not have thought of.

So thanks again and I welcome any and all feedback or other ideas from anybody and everybody else!

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Please tell me what part I have said is wrong (most part is accurate).  I have never said anything was "junk".  I have said some things may be "stuff" and when I say ""stuff", I mean it as equipment that isn't being used toward the contract, but laying around on the installation.  If GFP is provided to a contractor to be used for the contract, it should be listed as GFP.  It just requires a little work that many don't want to do to do the job right.  ;)  

 

 

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Guest Vern Edwards
On June 21, 2016 at 5:20 PM, Scorpimouse said:

We are currently re-competing a contract for Operation and Maintenance of a remote Air Force Station.  The Government owns a lot of property at the site that will be very useful to the winning contractor in performance of the contract (hand tools, maintenance equipment, shop stock, etc.). 

Quote

[T]his property is not officially accounted for anywhere in the Air Force except for the lists maintained on site - it's not in any database.

Why does it have to be provided as GFP or sold? Why can't it remain in government possession where it is and under whatever government control it's under now and just let the contractor draw from it in the course of operations? It sounds like a lot of stuff that doesn't merit capitalization--consumables and small tools in small quantities. It doesn't sound like stuff that will have a life beyond the life of the contract. If tallied it up, how much money would you be talking about?

Quote

So my question is, can we provide listings of all this property and have contractors bid in a "discount" to be able to take possession of it all?

Quote

We are thinking exactly of having a separate CLIN that will be "negatively priced." 

Discount bid and CLIN my a$$. Needless complexity and even potential basis for a claim. I'd just say in the SOW that the stuff is there and that the contractor can draw upon it as needed, and I'd put a memo in the file. That would be the end of it. Sounds like the contractor would be doing the government a favor. 

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Vern,

Normally I would agree with you, and that's how it's been done in the past.  The reason for the change is the Financial Improvement Audit Readiness (FIAR) requirements that basically says ALL Government property used on contracts needs to be accounted for in one central location for audit purposes.  The mechanism they are using for that is to attach all property to the contract as GFP and upload it into EDA.  It would be a violation of FIAR to have property that is just "there to be used" but not officially tracked anywhere or issued.

So, in light of FIAR, the only option is to put ALL contract-related Government property into EDA via the official GFP process.  However, it's not the intent of the FAR that ALL such property be actually issued as GFP, so the only way around it I see is to get it off our books.  The path we propose is a way to get it off our books while at the same time getting value back for the taxpayers.

I don't pretend to have all the answers.  Maybe I'm missing something in all of this or have misunderstood something.  If so, I welcome correction.

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Guest Vern Edwards

I haven't read the 320 page FIAR guidance.

  • Who told you that FIAR applies in this case?
  • What regulation or directive says that "all" government property used under a contract must be accounted for as GFP?
  • What's the total dollar value of the stuff?
  • Does each and every nut and bolt have to be accounted for?
  • Can you award the contract and then add the stuff later?
  • Can't you just manage it as government inventory issuance without making it GFP?

I guess the bottom line is that if you want to comply, then comply. But I would not do the discount/CLIN thing. If you don't have an accurate inventory of the quantity and condition of the stuff, and if the contractor later finds that everything is not as advertised in the RFP, then you might end up with a claim based on GFP. It might not be for a lot of money, but it might end up being a nuisance.

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Scorpimouse, Vern has asked pointed questions that need to be considered particularly 2 and 4.  Remember, the FIAR Guidance is not a procurement regulation.  In perusing the Guidance, it seems like the "stuff" (reminds me of the old George Carlin routine regarding stuff), would likely fall in the General Equipment definition which is the GE "consists of tangible assets that have an estimated useful life of 2 or more years; are not intended for sale in the ordinary course of operations; do not ordinarily lose their identity or become a component part of another item when put into use; and, are intended to be used or available for use by the reporting entity." If the stuff doesn't meet the 2 year minimum useful life or it loses its identity or becomes a part of another item, then the stuff is not GE and accountable as GE under the Guidance.  If you are being told it is accountable, ask as what category, then look up that discussion in the Guidance. 

On a final note, I don't see any requirements in the Guidance for placing property on a contract.

The Army has a property accountability regulation AR 735-5 which classifies property into three classes non-expendable, durable and expendable.  Formal accounting records are not required for durable or expendable property.  I am sure that the Air Force has a similar regulation.  It might be a good idea to check it out.

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Vern - Thanks for the pointers.  I'll keep them in mind as I continue my research.

Retreadfed - Thanks for the advice; good stuff.  This is the kind of helpful and useful information I knew this site would provide (from everybody).  I'll check into the Army regs.  It's been my experience that the AF usually has a slightly different, slightly more annoying way of doing things (but in a good way of course ;)).

To everybody - I appreciate your time and thoughtful consideration.  You have been very helpful to me.  Thanks again.  Any more ideas keep 'em coming!

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Scorpimouse:

You have mentioned that you don't clear the hurdles at FAR 45.102; however, since this is a maintenance effort the exception at FAR 45.102[d] may apply. This would eliminate a majority of the hurdles ... You mention you already have a list and pictures (read inventory).

Alternatively, since you seem to believe at least some of the government property isn't government furnished property as defined in FAR Part 45 ... why isn't it being treated as incidental pursuant to FAR 45.000[ b][5]? Seems like it could qualify based on what I've read here.

I offer this because maybe FIAR isn't as restrictive or prescriptive as it seems.

Does FIAR state where the central repository is and outline procedures for tracking. If not, what is the implementating guidance?

What if you had government property that was used on several contracts? Would each be uploaded in EDA?

 

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Jamaal - Good thoughts thanks.  This isn't a "repair" or "maintenance" contract in that sense, so that exception wouldn't apply.  It's more like a BOS contract where they "operate and maintain" the base, and by base I mean a small remote Air Force Station. 

I also wouldn't consider the property I'm talking about "incidental" as I believe the FAR defines that term.  Some things certainly are "incidental" and those will be provided as such ( tables, chairs, and large ovens and walk-in coolers in the industrial kitchen, etc.)  The stuff we're talking about here is things like shop stock (nuts and bolts, connectors, etc.), tools, extension cords, small appliances, spools of cable and wire, etc.

I believe FIAR requires EDA be the central repository, but I don't know for sure - I'm definitely still researching that stuff.  However I do know the Air Force has chosen to implement it by attaching the property to the contract and uploading to EDA. 

I believe property that is used in performance of a contract can only be assigned to one contract at a time, so there shouldn't be a case where multiple contracts are attaching the same property, resulting in a double-counting situation.

 

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  • 2 weeks later...
On ‎6‎/‎27‎/‎2016 at 8:48 PM, Scorpimouse said:

Jamaal - Good thoughts thanks.  This isn't a "repair" or "maintenance" contract in that sense, so that exception wouldn't apply.  It's more like a BOS contract where they "operate and maintain" the base, and by base I mean a small remote Air Force Station. 

I also wouldn't consider the property I'm talking about "incidental" as I believe the FAR defines that term.  Some things certainly are "incidental" and those will be provided as such ( tables, chairs, and large ovens and walk-in coolers in the industrial kitchen, etc.)  The stuff we're talking about here is things like shop stock (nuts and bolts, connectors, etc.), tools, extension cords, small appliances, spools of cable and wire, etc.

I believe FIAR requires EDA be the central repository, but I don't know for sure - I'm definitely still researching that stuff.  However I do know the Air Force has chosen to implement it by attaching the property to the contract and uploading to EDA. 

I believe property that is used in performance of a contract can only be assigned to one contract at a time, so there shouldn't be a case where multiple contracts are attaching the same property, resulting in a double-counting situation.

 

Navy is experience the same asset management policy, but I think the AF is ahead of the game. FIAR is a huge focus now. It will be interesting to see how it evolves and if it makes it way into acquisition regulations. This is an interesting post. Thanks for sharing. Please keep us posted on the strategy you take.  

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  • 3 weeks later...

Wow!!!  Lot’s of great discussions in this thread – and I hope that I am not toooo late to jump in and help!  Also, lot’s of interesting tangential items discussed in the thread – so I will stick to what I believe is the meat of the question.  And I only wish I could parse the question and responses down into their simplest statements – but that would take pages and pages.

 

O.k., first – all of the Government property on base needs to be accounted for if it meets the management requirement of DODI 5000.64. So you need to read the thresholds and criteria applied by the DoDI.  Not EVERYTHING goes into an Accountable Property System of Record.  The base or owning activity is required to establish and maintain an Accountable Property System of Record – an APSR.  Managed by an Accountable Property Officer – an APO.  And since this is Air Force, the AF uses the Air Force Equipment Management Systems (AFEMS) as its APSR.  (Don’t you just LOVE abbreviations?!?!?)  J

 

Next step -- If the Government wants to FURNISH all of the property as Government Furnished Property – then it must be LISTED in the solicitation and contract and for those of us in DoD – using the SGFP Attachments required by the DFARS PGI at DFARS PGI 245.103-72 – which mandates and calls out these forms!  Oh, and one small item – if the Government is going to FURNISH items that are NOT on an APSR – well, they need to be accounted for… Enclosure 3 of DoDI5000.64 states that, “DoD Components shall establish and maintain records and accountability for property (of any value) furnished to contractors as Government furnished property (GFP).”  So, it appears that even if the piddling stuff DID NOT meet the original requirements for an APSR – if furnished to the contractor – a RECORD needs to be established by the Government by the APO.

 

Potentially, the furnishing of this property as GFP could be justified under FAR 45.102 which is amplified by DoD in the DFARS PGI at 245.103-71 – providing some examples of when to do this.

 

Can the Government just “give” this Government Property to the Contractor?   NO!  FAR 45.6, and its statutory birth through the Federal Property Administrative Services Act of 1949, as amended, as well as the implementation under the GSA regs at FMR Subchapter B – Personal Property at 102-35 and 102-36 prescribe the REQUIRED ACTION before we can effect disposition of Government Property. http://www.gsa.gov/portal/ext/public/site/FMR/file/SubchB.html/category/21858/hostUri/portal

 

 

And no, you cannot just abandon the Government property on the base or installation as that would essentially be abandoning the GP to the Government…  Doesn’t make sense.

 

And you can’t just “transfer title” to all of the GFP to the contractor to “clean up the Government’s books.”  There is NO AUTHORITY to accomplish this act or action.

 

And some of this Government property may be “Incidental” to contract performance – as stated by others in the thread.  FAR 45.000.  It states, “(b) It [This FAR Part] does not apply to—

 (5) Government property that is incidental to the place of performance, when the contract requires contractor personnel to be located on a Government site or installation, and when the property used by the contractor within the location remains accountable to the Government. Items considered to be incidental to the place of performance include, for example, office space, desks, chairs, telephones, computers, and fax machines.”  And since specific detail as to this “stuff” was not provided – sorta’ tough to address that issue. 

 

But, with all of that said – you might want to check out FAR 52.245-2 which was written back in the 2007 FAR Government Property Rewrite for just such a situation. 

 

Conditions for use:

 FIXED PRICE CONTRACT

To be PERFORMED on a Government Base or Installation.

The GP is EXCESS to the needs to the Activity – in other words the AF no longer needs this Government Property to perform this function.  And I would assume that this is a function that might have been performed by Government employees in the past.

The GFP is furnished in an “AS IS, WHERE IS” condition (Of course allowing the prospective contractors to inspect it PRIOR to making their offer).

 

It is CRITICAL that a thorough review done to ensure that this Government Property really is no longer needed by the Government – AF in this case, at this location.  And is stuff that is truly EXCESS to the Government.  For example, the original intent of this clause was for items like Government owned lawn mowers, and leaf blowers and weed whackers.  When Government employees were performing this task – then those items were needed by the Government.  But when the Government contracted out this function – those items were NO LONGER needed by the Government, could be provided to a COMMERCIAL CONTRACTOR, on that “AS IS, WHERE IS” basis such that the Government obtained an economic benefit, with very little detriment versus if the Government furnished the property WITH the normal warranties of suitable for use and timely delivery of GFP – and the assumption of the limited risk of loss – under the GP Clause at 52.245-1.

 

So, this Government Property WOULD need to be listed in the contract as GFP, managed as GFP in accordance with the Government Property clause at 52.245-1 and associated DFARS Clauses related to GFP.  BUT, and here is the interesting part – if that GFP becomes damaged or destroyed or unserviceable – then:

The Government bears no requirement to replace or repair the item(s),

The Contractor STILL bears the responsibility to PERFORM the work and

The Contractor can go out and acquire whatever they need to perform the contract -- And anything acquired is THE CONTRACTOR’s PROPERTY – as this is a FIXED PRICE SERVICE type contract.

Lastly, the contractor needs to effect removal from the site and disposal of this unserviceable property.

 

And yes – even though this concern is in the PREAWARD stage – I would DEFINITELY solicit the assistance of a Government Property Administrator – a GS-1103 – to provide guidance in this area.  But, since you are on a base or installation DCMA does not pick up contract administration at these locations (See DCMA Instruction 124).  So I hope that there IS a Property Administrator at your location – from my experience -- there may not be.

 

Lastly, the issue of the Financial Improvement Audit Readiness (FIAR) is a whole nothing topic that could take pages to try and address – but I believe has minimal impact on the decision to furnish the GFP.  It does from a GOVERNMENT RECORDS perspective – internal to the Government – but less so on Contractors in their “stewardship” role.

 

Hope this helps a little!

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